Allegheny

Cardiolo,g1 f Associates
: Allegheny Pr9fessional .Building
, 490 East l~'.'orth Avenye, Suite 307

Health Netwo.rk
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Seema Verma, Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1716:.P
Mail Stop C4'-26-05 - ·.~ .. ·-~ ·
7500 Security Boulevard
, Baltimore, Maryland 21244-1850

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Re:

Fiscal Year 2020 Hospital Inpatient Prospective Payment Systems - CMS: 1716-P

Dear Administrator Verma:

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I appreciate the opportunity to provide comment on the FY20 IPPS Proposed Ruling.
As the
Director of the cardiac catheterization lab and interventional cardiology at Alleghi my General
Hospital (AGH) my primary goal is to ensure our patients have access to the right: care at the
right time for their disease state. AGH in Pittsburgh is one of the country's premijer health-care
institutions where talented and expert physicians and health-care professionals hi'i;re always
dedicated themselves to providing patients with innovative treatments, pioneerin,~1 research
discoveries, and exceptional medical care that is both personalized and compassic'.nate. AGH has
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576 licensed beds and approximately 800 physicians and 5,000 staff members.
are committed
to improving and maintaining the good health of people in our communities and ttilizing every
- possibl~ te~hnology, ~-;ource anc{tai'ent to tnake that happ~ri'.' - - . . ----...
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The treatment of cardiogenic shock (CGS) has largely been unchanged for many years and the
mortality of this patient population has stagnated at about 50%. In the three year:~l since Impella
(a percutaneous ventricular assist device) was PMA FDA approved for CGS, the.lmrvival rate has
improved to 67% and with implementation of a protocol-based approach, surviva:1 improved even
further to 82%. Impella is the most studied mechanical circulatory support device in the history
ofthe FDA and has exclusive PMA approvals to allow for native heart recovery with cardiogenic
shock derived from AMI or cardiomyopathy, and right sided heart failure.

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The FY20 Proposed Rule has a decrease of 29% on the reimbursement for DRG 2115, a DRG
where many of the cardiogenic shock patients discussed earlier land for billing pur1>0ses.
Reducing the payment for DRG 215 to a level below the cost of care would impair our hospital's
ability to manage the care and access to life saving devices. This would create an :1.ccess issue
and severely disadvantage the Medicare patient population.
I recommend that CMS mitigate this reduction by continuing the FY 2019 weight ofDRG 215
into FY20. I believe absent any change to the proposed rule to override this redudion, the
weighted payment rate for these procedures will create significant financial challef 1ges for
managing patients with advanced cardiovascular disease.
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I appreciate your attention to this matter.
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Sincerely,

David M. Lasorda, DO, ACC, FSCAI
Director of Cardiac Catheterization Laboratory
Allegheny General Hospital

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